Disclaimer

No Offer or Recommendation

The Website is for informational purposes only and should not be construed as a solicitation or offer, or recommendation to acquire or dispose of any investment or to engage in any other transaction in any jurisdiction.

No Reliance

While Ebullio Capital Management LLP uses reasonable efforts to obtain information from sources which it believes to be reliable, Ebullio Capital Management LLP makes no representation that the information or opinions contained in this Website is accurate, reliable or complete. The information and opinions contained in this Website are provided by Ebullio Capital Management LLP for personal use and informational purposes only and are subject to change without notice. You must in any event conduct your own due diligence and investigations rather than relying on any of the information on this Website. The investments or services referred to on this Website will not be suitable for everyone. If you have any doubts as to their suitability for you, you should seek advice from Ebullio Capital Management LLP.

Access and Own advice

Ebullio Capital Management LLP makes no representation that the information or materials on this Website are appropriate for use in all locations, or that any investments or services which are referred to on this Website are available in all jurisdictions, to everyone, or at all. In accessing this Website, you are responsible for compliance with local laws or regulations and for obtaining your own legal, tax and financial advice before entering into any transaction.

No Warranty

The material contained in this Website is for your private information and we are not soliciting any action based upon it. Opinions expressed are our present opinions only. The information herein has been obtained from, and opinions are based upon, sources believed to be reliable, but Ebullio Capital Management LLP does not represent that it is accurate or complete and it should not be relied upon as such and as such is provided without any warranty of any kind, express or implied.

Regulatory Information

Ebullio Capital Management LLP Limited is incorporated in the UK as a limited liability partnership (No. OC331213). Ebullio Capital Management LLP is authorised and regulated in the UK by the Financial Conduct Authority (FCA registration No: 486062). Ebullio Capital Management LLP is exempt from registration as a Commodity Pool Operator with the Commodity Futures Trading Commission ('CFTC') pursuant to CFTC Rule 4.13(a)(4) and exempt from registration as a Commodity Trading Advisor with the CFTC pursuant to CFTC Rule 4.14(a)(8).

Tax

The investments and other services and transactions referred to on the Website may have tax consequences and it is important to bear in mind that Ebullio Capital Management LLP does not provide tax advice. The levels and bases of taxation can change. You should consult your own tax advisers in order to understand any applicable tax consequences.

UK Stewardship Code Disclosure Statement

Under COBS 2.2 of the FCA Handbook, all FCA authorised firms are required to make a public disclosure in relation to the nature of their commitment to the above Code ("the Code") which was published by the Financial Reporting Council ("FRC") in July 2010.

The Code aims to enhance the quality of engagement between institutional investors and the companies they invest in with the intention of improving long term returns for shareholders and the efficient exercise of governance responsibilities. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. Firms may either comply with the Code or choose not to comply with certain aspects of the Code; in the latter case an explanation of non-compliance is required. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy.

Ebullio Capital Management LLP’s (“Ebullio") supports the principles of the Code, however due to chosen investment strategy, engagement does not occur and Ebullio does not consider that its clients expect such engagement. Should there be any material changes to the investment strategy of the Firm, which would render the Code relevant, this disclosure will be revised.

General public

All of the investments or services referred to on this Website are not available to the general public. Accordingly, access to information within this website is only available to qualifying investors who have accepted these Terms and Conditions and to whom Ebullio Capital Management LLP have issued a user name and password.

Limitations of Liability

Subject to the duties and obligations of Ebullio Capital Management LLP under the FCA rules, Ebullio Capital Management LLP will not be liable for any loss or damage suffered by you in connection with the services provided by Ebullio Capital Management LLP or your use of this Website, including without limitation: any indirect or consequential loss; any loss of profits or opportunity; any damage to business or reputation; any loss or damage resulting from or related to use of or inability to use any material posted or transmitted on or via this Website; any loss or damage arising out of or in connection with the access of, use of, performance of, browsing in or linking to other sites from this Website or reliance on any information contained on this Website, except to the extent that such loss or damage arises directly from the gross negligence, fraud or wilful default of Ebullio Capital Management LLP.

Privacy Statement

These policies apply to individuals only and may be changed at any time, provided a notice of such change is given to you. We do not disclose any of the personal information you have supplied us when registering for access to our Website to anyone, other than to our affiliates, and except as permitted by law, such as to our attorneys, regulators and certain service providers, in such case, only as necessary to facilitate the acceptance and management of registration to this Website. We will also release information about you if you direct us to do so, if compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation. We may also disclose information you provide to us to companies that perform marketing services on our behalf. If such a disclosure is made, Ebullio Capital Management LLP will require such third parties to treat your private information with confidentiality. We seek to carefully safeguard your private information and, to that end, restrict access to non-public personal information about you to those employees and other persons who need to know the information to enable Ebullio Capital Management LLP to provide our services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal information.

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Pillar 3 Disclosure

Disclosure Policy

The Pillar 3 rules in BIPRU 11 set out the need for firms to have a formal disclosure policy. In accordance with the rules of the Financial Conduct Authority (“FCA”) Ebullio Capital Management(the “Firm”) will disclose the information set out in BIPRU 11 (the Pillar 3 rule) on at least an annual basis.

The Firm may omit information it deems as immaterial, in accordance with the rules. Materiality is based on the criterion that the omission or misstatement of any information would be likely to change or influence the decision of a reader relying on that information. Accordingly where the Firm has considered an item to be immaterial it has not been disclosed.

In addition, if the required information is deemed to be proprietary or confidential then the Firm may take the decision to exclude it from the disclosure. In the Firm's view, proprietary information is that which, if it were shared, would undermine its competitive position. Information is considered to be confidential where there are obligations binding the Firm to confidentiality with our customers, suppliers or counterparties. Where information is omitted for either of these reasons this is stated in the relevant section of the disclosure, along with the jurisdiction.

Introduction

The Firm is authorised and regulated by the FCA and as such is subject to minimum regulatory capital requirements. The Firm is categorised by the FCA, for capital purposes, as a BIPRU firm. It is an investment management firm and has no trading book exposures. The Firm is not required to prepare consolidated reporting for prudential purposes.

The FCA’s current prudential regime can be split into three “pillars”:

Pillar 1 – prescribes the minimum capital requirements that authorised firms need to hold. This is the higher of €50k; quarter of the firms annual adjusted expenditure (the Fixed Overheads Requirement); or the sum of the firm’s prescribed Credit risk + Market risk.

Pillar 2 – requires firms to analyse the risks to the business and then consider whether the risks are mitigated to an appropriate standard. If the firm feels that the risks are not adequately mitigated then they should allocate capital against those risks. Stress and scenario tests are conducted to ensure that the processes, strategies and systems are comprehensive and robust and that the allocation of capital is sufficient.

Pillar 3 - requires firms to develop a set of disclosures which will allow market participants to assess key information about the Firm’s underlying risks, risk management controls and capital position.

The Firm is a Limited Liability Partnership and its capital arrangements are established in its Partnership deed. Its capital is summarised as follows:

£000’s

Members’ capital

Revenue reserves

-------

Members’ capital and other reserves 3,266

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The main features of the Firm’s Capital Resources Requirement are as follows:

Capital Item

£’000s

Tier 1 capital less innovative tier 1 capital

3,245

Total tier 2, innovative tier 1 and tier 3 capital

21

Deductions from tier 1 and tier 2 capital

Total capital resources, net of deductions

3,266

Risk Management

Due to the size, nature, scale and complexity of the Firm, there is no independent risk management function. The Partners of the Firm determine the business strategy and risk appetite along with the risk management policies and procedures. Risks to the Firm are identified and considered and the Firm’s resultant exposure is assessed after the application of both management and mitigation of these risks. Furthermore the Firm then conduct a series of stress tests and scenario analyses on these risks to determine the effect they would have on the firm.

If necessary the Firm would allocate extra capital to the relevant risk, as per the Pillar 2 requirement: this has not been deemed necessary. This process is conducted at Partners meetings which are held on a quarterly basis and the relevant policies and procedures are updated where necessary.

The Partners have identified operational risk as the main area of risk to which the firm is exposed.

The Firm has concluded that its Tier 1 capital is sufficient to cover its Pillar 1 and Pillar 2 requirements.